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Home My WebLink About05-6209 . ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Mortgage Electronic Registration Systems, Inc. 4828 LOOp Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAf CIVIL DIVISION Cumberland County I I v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 0 5' - Io:J.Cf1 C.L (J', L ~82..~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend gainst the claims set forth in the following pages, you must ake action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by a torney and filing in writing with the Court your defenses or objec ions to the claims set forth against you. You are warned that if ou fail to do so the ease may proeeed without you and a j udg ent may be entered against you by the Court without further not ce for any money claimed in the Complaint or for any other clai or relief requested by the Plaintiff. You may lose money or roperty or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH B LOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY FFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO F E. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . AVISO Le han demandado a usted en la corte. Si usted quier~ defenderse de estas demandas expuestas en las paginas siguientes, iusted tiene veinte (20) dias de plaza al partir de la fecha de la 4emanda y la notificacion. Hace falta aseentar una comparencia elscrita 0 en persona 0 con un abogado y entregar a la corte en forma lescrita sus defensas a sus abjeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomata medidas y puede continuar la demanda en contra suya sin pre"fio aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las pr visianes de esta demanda. Usted puede perder dinero 0 sus propied des u otros dereehos impartantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO T ENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVI 10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA D RECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUED CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 717-249.3166 800.990-9108 . NOTICE The amount of your debt is as stated in the attached document. The na~e of the creditor to whom the debt is owed is as named in the attached document. Unless youlnotify us within 30 days after receipt of this Notice and the attached document that the vali4ity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verificati n of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute t e debt, it is not an admission of liability on your part. Also, upon your written request w thin the 30 day period, we will provide you with the name and address of the original creditor f different from the current creditor. If you notify us in writing within the 30 day period as stated above, we wil cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required informati n, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attac ed document is an attempt to collect a debt, and any information obtained will be used for t at purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the on a preceding page. If Plaintiff is an assignee then it by virtue of the following recorded assignme~ts: caption is such Assignor: N/A Assignments of Record to: N/A Recording Date: N/A 2. Defendant(s) is the individual designated as sueh on the eaption on a preeeding page, whose last known addres is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being forec osed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plain iff) loaned to the Defendant (s) the sum appearing on said Mort age, which Mortgage was executed and delivered to Plaintiff as s curity for the indebtedness. Said Mortgage is incorporate herein by reference in accordance with Pa.R.C.P. 1019 (g) The information regarding the Mortgage being forec osed is as follows: MORTGAGED PREMISES: 121 North MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 03/24/04 DATE RECORDED: 04/15/04 BOOK: Sporting Hill Road Hampden Township 1860 PAGE: 4825 The legal description of the mortgaged premises is atta hed hereto and made part hereof. 4. Said Mortgage is in default because the requi ed payments have not been made as set forth below, and by its erms, upon breaeh and failure to eure said breach after notice, all sums secured by said Mortgage, together with other charges au horized by said Mortgage itemized below, shall be immediately du 5. After demand, the Defendant (s) continues ~o fail or refuses to comply with the terms of the Mortgage as fot10WS: (a) by failing or refusing to pay the insta~lments of \ , prineipal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charg~s, if any, indicated below. , 6. The following amounts are due on the said Mottgage as of 11/10/05 : Principal of debt due Unpaid Interest at 8.7% * from 6/1/05 to 11/10/05 (the per diem interest accruing on this debt is $25.08 and that sum should be added each day after 11/10/05) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $129.82 and that sum should be added on the first of each month after 11/10/05) $103,853.42 4,088.04 325.00 280.00 396.90 Late Charges (monthly late charge of $49.24 should be added in accordance with the terms of the note each month after 11/10/05) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 196.96 * This interest rate is subject to adjustment as mor forth in the Note and Mortgage. 7. The attorney's fee set forth above formity with the mortgage documents and Pennsylvania law, and will b colleeted in the event of a third party purchaser at Sheriff's S Ie. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction pr visions of 5,192.67 114,332.99 fully set Act 6, if applicable. 8. The combined notice specified by the Homeowner's Emergency Mortgage Assistance Program, Actl 91 of and Notice of Intention to Foreclose under Act 6 of 19f4 has sent to each defendant, via certified and regu1a1 mail, 1983 been in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed with~n the time limits, or have been determined ineligible, or Plainqiff has not been notified in a timely manner of Defendant(s) elig~bility. WHEREFORE, the plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $114,332.99 pl s interest, costs and attorneys fees as more fully set forth in th Complaint, and for foreclosure and sale of the Mortgaged premise Mark J. Udren, ESQ UDREN LAW OFFICES, Attorney for Plain Attorney I.D. No. IRE P.C. iff 4302 ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN HAMDEN TOWNSHIP, CUMBBRLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH SURVEY AND PLAN THEREOF MADE BY GERRIT J. BETZ, REGISTERED SURVEYOR, DATED April 16, 1979, AS FOLLOWS: BEGINNING AT A POINT MARKED BY AN IRON PIN, ON THE WESTERN,,SIDE OF SPOIfTING HILL ROAD, SAID POINT BEING 100 FEET SOUTH OF THE SOUTHWEST CORNER OF SPORT~NG HILL ROAD AND AN UNNAMED STREET, THENCE ALONG THE WESTERN SIDE OF SPORTING HILL OAD, SOOTH 18 DEGREES 30 MINUTES WEST, 73 FEET TO AN IRON PIN AT A CORNER OF LAND FORMERLY OF A. L. RONK AND NOW OR LATE OF L. GILMORE, THENCE ALONG SAID LAND NORTH 71 DEGREES 30 MINUTES WEST, 165 FEBT TO A STAKE IN LINE OF LAND NOW OR LATE OF RO ALD DEBOARD, THENCE ALONG SAID LAND AND LAND NOW OR LATE OF JENTRY, NORTH 18 DEGREE 30 MINUTES EAST, 73 FEET TO AN IRON PIN AT A CORNER OF LAND FORMERLY OF HARRY BO RS, NOW OR LATE OF CLARENCE GRIMM, THENCE ALONG SAID LAND, SOUTH 71 DEGREES 30 MI ES EAST, 165 FEET TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 12 AND THE NORTHERN 23 FEET OF LOT NO. 13 ON THE PLAN OF ENTITLED PLAN NO. 2 OF BUNGALOW SITES, WHICH PLAN IS RECORDED IN THE C COUNTY RECORDER'S OFFICE IN PLAN BOOK 3, PAGE 24. HAVING THEREON ERECTED A ONE-STORY STUCCO AND FRAME DWELLING KNOWN AS SPORTING HILL ROAD. O. 121 N. ONDER AND SUBJECT, NEVERTHELESS, TO RESTRICTIONS, RESERVATIONS AND CO CONTAINED IN PRIOR tNSTROMENTS OF RECORD. ITIONS AS THE SOUTHERN LINE OF THE ABOVE DESCRIBED PREMISES PASSES THROUGH THE C THE WELL LOCATED ON,LOT NO. 13. THE SAID WELL TO BE USED JOINTLY BY T HEREIN, HIS HEIRS AND ASSIGNS, AND THE OWNERS OF OCCUPIERS OF THE SOOT LOT NO. 13 AND LOT NO. 14 ON THE ABOVE MENTIONED PLAN. NTER LINE OF GRANTEE ERN PART OF I I (Page] of 6) I /is LITTON LOAN SERVICING LP An Affiliate orC-BASS I Telep~One 800-999-8501 . Fax 713 966 8906 4828 Loop Central Dr, Houston, Texas 77081 www.littonloaILcom Jimmy Betz Jody Betz 121 N Sporting Hill Rd Date: ~/6/2005 Page 110f 5 I I , I Mechanicsburg, P A 17050 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort a e on our home is in default and the lender iute ds to foreclose. S eeific information about tbe nature of tbe default is Drovided in tbe attached na2es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM EMAP ma e ahle to belD to save vour home. This Notice exnlains bow to ol"Ol!ram work.,- To see if HEMAP can bel vou must MEET WITH A CONSUMER CREDIT COUNSE ING AGENCY WITH IN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou wbeD ou eel with the Counselin A~eDC\'. The name, address and phone number of Consumer Credit Counseling Agencies serving y ur County are li4ilted at tbe end of the Notice. If you have any questions, YOD may call tbe Penusylvania Housing Fi ance Agency toll free at I-800-342-2397.(persons with impaired bearing can call (71 7)780-18 9. This Notice contains important legal information. If you have any questions, represent tives at the Consumer Credit CODnseling Agency may be able to belp explain it. YOD may also want to eontact a attorney in your area. Tbe local bar association may be able to belp you find a lawyer. LA NOTIFCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DE ECHO A CONTINUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFIC CION OBTENGA UNA TRADUCCION lNMEDITAMENTE LLAMANDO ESTA AGENC1A (pENNSYLVANIA HOUS G FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRffiA. PUEDES SER ELEGffiLE PARA PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PR M" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT p. (Page 2 of 6) APPENDIX A Page 2 of5 HOMEOWNER'S NAME(S): Jimmy Be17. Jody Betz MAILING ADDRESS: 121 N Sporting Hill Rd Mecbanicsbu rg, P A 170502454 PROPERTY ADDRESS: 121 N Sporting Hill Rd Mechanicsbu'1\. P A 17050 LOAN ACCT. NO.: 12224184 ORIGINAL LENDER: CURRENT LENDER/SERVICE: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PR( GRAM YOU MAYBE ELIGffiLE FOR FINANCIAL ASSISTANCE WInCH CAN SAVE YOUR HOME "'OM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORT AGE ASSISTANCE ACT OF 1983 (I'HE "ACT"), YOU MAY BE ELIGffiLE FOR EMERGENCY MORTGAGE ASSISTAN E: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HA VF, A REASONABLE PROSPF.cT OF BEING ARI,F, TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELEGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOllSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act you are entitled to a tem~ rary stay of foreclosure on your mortgage for thirty (30) days from the dale of this Notice. During that time you must arrange and attend a "face-tn-face" meeting with one of the consumer credit counseling agencies listed at the end of the Notice TillS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU 0 NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORT( AGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MO TGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one f the cousumer credit counseling agency listed at the end of this notice, the lender may NOT take action ag linst you for thirty (30) days after the date of this meeting. The names "~dresses and telenhone numbers of de ionated consumer credit counselln" a"eucies for the countv in which the nronerlv is located arc set forth at the end of this Notice. It is ooly necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your ntentions. APPLICA nON FOR MORTGAGE ASIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonuation about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistan e from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out. sign and fIle a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit CODuse . ng ageucies listed at the (Page 3 of 6) APPENDIX A Page30fS end of this Notice. Only consumer credit counseling agencies have applications for the program and Uley will assist you in submitting a complete application to !be Pennsylvania Housing Finance Agency. Your application MUST be fIled or postmarked within thit1y (30) days of your face-to-face meetiDg. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAlL TO DO SO OR IF YOU ~O NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED jl,GAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DE~D. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They Will be disbursed by !be Agency under U,e eligibility criteria established by !be Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. Durin that time, no foreclosure proceedings will be pursed against you if YOD have met the time requirements set forth ab ve. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BAM RUPTCY, THE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMA nON PURPOSES ONLY AND SH( ULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mo~age Assis nee.) HOW TO CURE YOUR MORTGAGE DEFAULT !Brinn it un to da e\ NATURE OF THE DEFAULT The MORTGAGE debt held by !be above lender aD your pro et1y located at: 121 N Sporting Hill Rd IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the follow. ng months and the following amounts are now past due: 7/1/2005 throuoh 9/1/2005 at $950.55 totaling $2.851.65 Other charges Late Charges $ 98.48 Deferred late charges $ 147.72 TOTAL AMOUNTPASTDUES2,980.29 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 100 not use if not on licable': HOW TO CURE THE DEFAULT You may core !be default within THIRTY (30) DAY of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, wmCH IS $$2,980.29 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES wmCH BECON E DUE DURJNG THE TIllRTY (30) DAY PERIOD. Pavments must be made eitherbv cash cashier's check. cert. led check or money order made oavable and sent to: Litton Loan Sen'icino LP 4828 Loon Central Dr Houston TX 77081- 226. , YOD can cure any other default by taking the following action within THIRTY (30) DAYS of~e date oftbis letter: ill!! not use nno! annlicable.) ! (Page 4 of 6) APPENDIX A Page 4 of5 IF YOU DO NOT CURE THE DEFAULT -If you do not cure the default witlrin THIRTY (30) DAYS of the date o[ this Notice, the lender intends to exercise it!ri rit!hts to accelerate the mortt!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of tile total amonnt past due is not made within THlRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal actiou to foreclose upon vou~ mort2a2ed propertv. IF TIlE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt If the lender refen; your case to its attorneys, but you eure the delinquency befdre the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that wele actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonabfe attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorney's fees will be added to the amount you owe the lender. which may also include other reasonable cost If vou cure the defaDlt within the TH RTY 30 DAY eriod vou will not be reouired to nav attomev's fees. OTHER LENDER REMEDIES - The lender may also sue you pen;onally for the unpaid prin ipal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -If you have not c d the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, au still have the ri t to cure the default and revent the sale at anv time u to one hour before the Sheriff's Sale. You do so b a in the total amount then as! due Ius late or other char es then due reasonable attorne 's fees and costs couoecte with the foreclosure sale and a other costs couoected with the SheriiT's Sale as ecified in writiu b the leuder an b erformln an other reauirements under the mortl!3l!e. Curing your default in the manner set forth in this otice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S DATE It is estimated that the earhest date that sue as Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of thi Notice. A notiee of the actnaJ date of the Sheriff's Sale will be sent to you before the sale. Of course. the amount ded to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LITfON LOAN SERVICING Address: 4828 Loop Central Dr, Houston, TX 77081 Phone Number: (800)999-8501 or (713) 960-9676 Fax Number: (713) 966-8906 Contact Person: Collection Department EFFECT OF SHERIFF'S SALE - You sliould realize that a Sheriffs Sale will end your 0 uen;hip of the mortgaged property and your right tu occupy it If you continue tu hve in the property after !be Sheriff's Sale, a lawsuit to remove you and your furnishings and o!ber belongings could be started by the lender at auy time. ASSUMPTION OF MORTGAGE - You _ mayor _ may not (CHECK ONE) sellfr transfer your home to a buyer or transferee who will assume !be mortgage debt provided that all the outstandi g payments, charges and attorney's fees and costs arc paid prior to or at the sale and that the other requirements of the mo gage are satisfied. Page 5 of 6) APPENDIX A Page 5 of5 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION 110 PAY OF THIS DEBT. TO HAVE TIllS DEF AUL T CURED BY ANY TIllRD PARTY ACTING ON ivOUR BEHALF. , TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS ~. NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT (HOWEVER, YOU DO NO HAVE TIllS RJGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALE DAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLO URE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DO< UMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE T SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY 'Fill in a li,t of all Counselino Aoencies listed in Annendix C FOR THE COUNTY in hich the nronertv is located. usinl! additional D3l!eS if necessarY). CumberlandCountv CCCS of Western Pennsvlvania. Inc. 2000 Linl!1estown Road Harrisbul'l!.PA 17102 (717(541-1757 Financial Counselin2 Services of Fr nklin 31 West 3rd Street Wavnesboro. P A 17268 (717)762-3285 Urban Lea2Ue of MetroDOlitan Harrisbur2 N. 6th Street Harrisbul'l!. P A 17101 (717)234-5925 FAX(717)234-9459 YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(717l731-9589 (Page 6 of 6) Communitv Action Comm of the CaDital Re2ioD 1514 Derrv Street Harrisbul'1!.PA 17104 (717)232-9757 FAXJ(17)234-2227 Adams Countv Housin~ Authoritv 139-143 Carlisle St Gettvsbul'1!. P A 17325 (717)334-1518 FAX(717)334-8326 (Page 1 of 6) /is LITTON LOAN SERVICING LP An Affiliate orC-BASS 4828 Loop Central Dr, Houston, Texas 77081 www.littonloancom Telephone 800-999.8501 Fax 713 9668906 Jimmy Betz Jody Betz 121 N Sporting Hill Rd Date: P/6/2005 Page l'of5 Mechanicsburg, P A 17050 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort a eon vour home is in default and the lender inte ds to foreclose. S ecific information about the nature oftbe default is Drovided in the attached Da2es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP ma e ahle to heln to save vour home. This Notice exnlaios how to nrof!ram work.~. To see if HEMAP can bel VOD must MEET WITH A CONSUMER CREDIT COUNSE ING AGENCY WITH IN 30 DAYS OF mE DATE OF THIS NOTICE. Take tbis Notice with ou when ou eel with the Counselin Af!encv. The name, address and phone number of Consumer Credit Counseling Agencies serving y ur Count3" are li~ted at the end of tbe Notice. If you bave any questions, YOD may call tbe Pennsylvania Housing Fi ance Agency toll free at 1-800-342-2397.(persons with impaired hearing can call (717)780-18 9. This Notice contains important legal infonnation. If you have any questions, represen Credit CODnseling Agency may be able to help explain it. You may also want to contact The local har association may be able to help YOD rmd a lawyer. tives at the Consumer attorney in you r area. LA NOTIFCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DE ECHO A CONTINUAR VIVIENDO EN SU CASA SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIF1C CION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUS G FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRmA PUEDES SER ELEGmLE PARA PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PR RAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA (Page 2 of 6) APPENDIX A Page 2 of 5 HOMEOWNER'S NAME(S): Jimmy Ben Jody Betz MAILING ADDRESS: 121 N Sporting mil Rd Mechanicsbu rg, P A 170502454 PROPERTY ADDRESS: 121 N Sporting Hill Rd Mechanicsbu rg, P A 17050 WAN ACCT. NO.: 12224184 ORIGINAL LENDER: CURRENT LENDER/SERVICE: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PR GRAM YOU MAY BE ELlGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORT AGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTAN E: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HA VF.. A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELEGIBILlTY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOL'SINGFINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are eutitled to a tem~ nuy stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies isted at the end of the Nolice. TillS MEETING MUST OCCUR WITHIN THE NEXT 130. DAYS. IF YOU 0 NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORT( AGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MO TGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one (f the consumer credit counseling agency listed at the end of this uotice, the lender may NOT take action ag . nst you for thirty (30) days after the date of this meeting. The names. addresses and telenhone numbers of de i'nated consumer credit couuselin~ a~encies for the couutv in which the nro""rtv is located are set forth at the end f this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your . ntentions. APPLICA nON FOR MORTGAGE ASISTANCE-Your mortgage is in default for the -easons set forth later in tlns Notice (see following pages for specific information about the nature of your default.) or you have tried and are unable to resolve this problem with the lender, you have the right to apply for fInancial assistan e from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fIll out, sign and me a completed Homeowner's Emergency Assistance Program Application witb one of the designated consumer credit counsel ng ageucies listed at the (page 3 of 6) , ' APPENDIX A Page 3 of5 end of Uris Notice. Only consumer credit counseling ageucies have applications for !he program and they will assist you in submitting a complete application to !he Pennsylvania Housing Finance Agency. Your application MUST be filed orpostroarked wiUrin Urirty (30) days of yo or face-to-face meeting. YOU MUST FILE YOUR APPUCATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU 1>0 NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECWSURE MAY PROCEED ~GAlNST YOUR HOME IMMEDIATELY AND YOUR APPUCA TION FOR MORTGAGE ASSISTANCE WILL BE DENntD. AGENCY ACTION - Available funds for emergeucy mortgage assistance are very limlted. They Will be disbursed by the Agency under the eligibility criteria established by the Act. The i Permsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. DUrinrthat time, no foreclosure proceedings will be pursed against you if you have met the time requirements set fortb ab ve. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOUR ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANrUPTCY, THE FOLLOWING PART OF TIllS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SH ULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (lfyou have filed bankruptcy you can still apply for Emergency Mort~a~e Assis nee.) HOW TO CURE YOUR MORTGAGE DEFAULT Bnn it u to da e . NATURE OF THE DEFAULT The MORTGAGE debt held by the above lender on your pro erty located at: 121 N ~_~M I I IS SERJOUSLY lNDEFAULTbecause: I A. YOU HAVE NOT MADE MON1HL Y MORTGAGE PAYMENTS for the followi g months and the following amounts are now past due: 7/112005 throu~h 91112005 at $950.55 totalin~ $2.851.65 Other charges Late Charges $ 98.48 Deferred late cliar.es $ 147.72 TOTAL AMOUNT PAST DUE $2,980.29 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 0 not use if not a licable: HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAY notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECO lHIRTY (30) DAY PERJOD. Pavments must be made eilherbv cas casbier's check cert. made oavable and sent to: of the date of this CH IS $$2,980.29 DUE DURING THE ed check or monev order Litton Loan Servicin LP 4828 Loa Central Dr Houston TX 77081- 226. You can cure any otber default by taking tbe following action within THIRTY (30) DAYS of lhe date of this letter: Q2Q. not use if not anulicable.) i (Page 4 of 6) , ' . APPENDIX A Page 40f5 IF YOU DO NOT CURE THE DEFAULT -If you do not cure the default wiUrin THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri!!hts to accelerate the mortt!ae:e debt. This means that the entire outstanding balance of this debt will be considered dne immediately and YOD may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within TflIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose uoon vout mortl!al!ed orooertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by tlhe Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys. but yon cure the delinquency before tlie lender begins legal proceedings against yo~ you will still lie required to pay the reasonable attorney's fee that were actually incurred. up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasona1l1e attorney's fees actually incurred by the lender even if the exceed $50.00. Any attorncy's fees will be added to the amount yon owe the lender, which may also include other reasonable cost. H ou cure the defaDlt within the T RTY 30 DAY eriod vou will not be reouired to OS" sttornev's fees. I i OTHER LENDER REMEDIES - The lender may also sne you personally for the unpaid prin~iPal balance and all other sums due under the mortgage. ! RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not c ed the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, on still have the ri ht to cure the default and revent tlie sale at a time u to one hour before the Sheriffs Sale. You do so b a in the total amonnt then ast due Ius an late or other c es then due reaso ble attome 's fees and costs cohuecte with the foreclosure sale and an other costs cotmeCted with the Sheriff's Sale as s cified in writin b the lender an bv erfonnin an other reauirements under the morte-age. Curing your default in the manner set forth in this notice will restore your mortgage to tbe same position as if you bad never defaulted. : EARLIEST POSSIBLE SHERIFF'S DATE - It is estimated that the earliest date t1lat SU~l as Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of th s Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount eeded to cure the default will increase the longer you wait. You may find out at any time exactly what the require payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: LITTON LOAN SERVICING Address: 4828 Loop Central Dr, Houston, TX 77081 Phone Number: (800)999-8501 or (713) 960-9676 Fax Number: (713) 966-8906 Contact Person: Collection Department ~ EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your 0 nership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at aoy time. I ASSUMPTION OF MORTGAGE - Y ou ~ may or ~ may not (CHECK ONE) se~or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstandi g payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the m , rtgagc are satisfied. (Page 5 of 6) Jl . \ . APPENDIX A Page 5 of5 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAJN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OF THIS DEBT TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON 'YOUR BEHALF TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS If NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOll DO NOt HAVE THIS RlGfIT TO CURE YOUR DEFAULT MORE 1HAN THREE TIMES IN ANY CALE~DAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECL~SURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DO~UMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TI SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. I ! CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR C( UNTY IFill in a list of all Counselin. A.enci.. listed iD ADDendi. C FOR THE COUNTY in hich the orooertv is located. usim! additional na!!es if necessan'). CumberlandCountv CCCS of Western Pennsvlvania. Inc. 2000 Lin21estown Road Harrisbul1!.PA 17102 17171541-1757 Financial Counselinl' Services of Fr nklin 31 West 3rd Street Wavnesboro. PA 17268 (717)762-3285 Urban Lea2De of MetroDolitan Harrisbur2 N. 6tb Street Harrisbul1!. P A 17101 (717)234-5925 FAX(717)234-9459 YWCA of Carlisle 3001 G Street Carlisle. PA 17013 (717)243-3818 FAX(7I7)731-9589 (Page 6 of 6) . Communitv Action Comm of the Caoita. Re!!ioD 1514 DeT", Street HaTrisbuT2. P A 17104 (717)232-9757 FAX(717)234-2227 Adams Counh Housint! Authoritv 139-143 Carlisle St Gettvshul1!. P A 17325 (717)334-1518 FAX(717)334-8326 . . . V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated oth~rwise; that he is authorized to take this Verification and does s~ because of the exigencies regarding this matter, and because Plaiintiff must verify much of the information through agents, and be ause he has personal knowledge of some of the facts averred in th foregoing pleading; and that the statements made in the foregoi g pleading reports of Plaintiff's agents, The undersigned and are true and correct to the best of his knowledge, inf belief and the source of his information is public and tands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsif'cation to authorities. Mark J. dren, ESQ IRE UDREN LAW OFFICES, P.C. ~ "6Q. 8 7::.J ~ 01 , '-"'i1, \t U\ ('~, .-' , >;:-'1 -~.~ I'"~ U1 'C) " - ~ ~ f') ~ - " ~ .t: r Vt - W ,- ~ , (,;. -L... SHERIFF'S RETURN - REGULAR CASE NO: 2005-06209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BETZ JIMMY L ET AL CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BETZ JIMMY L the DEFENDANT , at 1817:00 HOURS, on the 19th day of December, 2005 at 121 NORTH SPORTING HILL ROAD MECHANICSBURG, PA 17050 by handing to JIMMY BETZ, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Aft idavi t Surcharge So Answers: 18.00 11.52 .00 10.00 .00 39.52 .<" _,.-;.::;::::F'-(~~,::'<' ::-;" .r ...~..~:,_.,~ R. Thomas Kline 12/20/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: ---" --c"1 ,/ -::::;-" --:1:"/</ --........ . /z?<(,,// Sheriff me this /, """, '; day of ty '-~'-'" ~'t,2OC~ fJ~ty A.D. . SHERIFF'S RETURN - REGULAR . CASE NO: 2005-06209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BETZ JIMMY L ET AL CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BETZ JODY M the DEFENDANT , at 1817:00 HOURS, on the 19th day of December, 2005 at 121 NORTH SPORTING HILL ROAD MECHANICSBURG, PA 17050 by handi.ng to JIMMY BETZ, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 .,..", R. Thomas Kline '-;:." .- ., , 12/20/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: --,. 1 ~ /-...-:1.' ~;' J- ft~.>/ / ty Sheriff "- me this 'I - day of "\ -~r~~ A.D. .---'."'. . . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Jimmy L. Betz and Jody M. Betz for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 11/11/05 to 1/24/06 Late charges per Complaint From 11/11/05 to 1/24/06 Escrow payment per Complaint From 11/11/05 to 1/24/06 TOTAL $114,332.99 3,360.72 147.72 259.64 $116,621.35 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES. P.C. DAMAGES ARE HEREBY ASSESSED AS DATE :-... ):::1. , .;; / ;) I'){)fc, I INDICATEn ' ,1 '"0 p~'i~1 . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, COURT OF COMMON PLEAS Inc. CIVIL DIVISION Plaintiff Cumberland County ATTORNEY FOR PLAINTIFF v. Jimmy L. Betz Jody M. Betz NO. 05-6209 civil Defendant(s) Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 DATE of Notice: January 11, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, US TED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. s . ren, B.;squlre Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Mortgage Electronic Registration Systems, COURT OF COMMON PLEAS Inc. CIVIL DIVISION Plaintiff Cumberland County ATTORNEY FOR PLAINTIFF v. Jimmy L. Betz Jody M. Betz NO. 05-6209 Civil Defendant(s) Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 DATE of Notice: January 11, 2006 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAI.NE.D W0L BE USED FOR THAT PURPOSE. \ r r . I , ! s .. ren, Esqul.re Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 > . UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Jimmy L. Betz Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Jody M. Betz Over 18 As captioned above Unknown Name: Title: Company: N, SQ. TORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. _lift NI_III'WCf( _IWICCW... ..., , .. ......."'1,. t~ 3- ~ ~ ~ ~ t-- (.) "\L D \) V'l r -t;). ..(', \> C> ~ ~ ..J.---- --l... n (: "" C7".::J. .c-';;':" a'> ,- 1"; ~, ..i#\ "".( ,';' ,,' (,'J, , > . ~ ,'"At' ,,,.., ~;. - t ::-,... ~ o -n -l X-n rl111 :~~~~ ".1;1 ";~~~\ :~j "n :< w ::t"'!1< :-.,,.. .,...;''''" o if-'O.. ,~ .. :'t", ':"'. - " . . -I. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil TO: Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -K- Judgment by Default Money Judgment Judgment in Replevin I/JI/Ob Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, ESQuire At this telephone number: 856-669-5400 F ~ ' . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil TO: Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary -K- Judgment by Default Money Judgment Judgment in Replevin I/:l/jot.,. Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $116.621.35 Interest From 1/25/06 3,360.72 to Date of Sale 06/07/06 Ongoing Per Diem of $25.08 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. \ . ./""\ 1\ /\ ~ Udr~ ES~R~ TT EY FOR PLAINTIFF . -.xJ ~ 0 ~ -<q, y:j --- \ ~ \\:- B \) ~ () ,... t? ~ D ( f \) t \t'l ~ C> + H t r .~ - ~ b"j tr\ W ~ --- 4 ..0 lrl ~ ..0 U\ V) l/l C> ~ () lr} 0 ?J () () C c ~ \) , "'" 0 ~ C'"...J G (.'_~-'Jl -n 0~ '- .-1 0 :l: ::-= n'~ - -~ - ~ ~ "ntT1 - ::. '-.J ":lJl? - '::: ::: - c;Jt ';~';f~, - p '--,'t - - ~r :?;: :~::~~ - - - - - - .- :::0- Co :n r-..', '-< --------- ./..--- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-6209 Civil CIVIL ACTION - LAW TO THE SHERJFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC., Plaiutiff (s) From JIMMY L. BETZ AND JODY M. BETZ (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant( s) not levied upon in the possession of GARN1SHEE(S) as follows: and to Dotify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlber that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $116,621.35 L.L. $.50 Interest FROM 1/25/06 TO DATE OF SALE 617106 - ONGOING PER DIEM OF $25.08 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,360.72 Ally's Comm % Due Prothy $1.00 Atty Paid $137.52 Plaintiff Paid Date: JANUARY 31, 2006 Other Costs (Seal) Pr By: Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NO. 05-6209 Civil Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ',,- UDREN LAW OFFICES, P.C. ~^^ Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF C) ~J 0 -:::;;;:} c: ~ -n cr' (7 <- ::;:I J:~ f'n~ :.1'~ -nm W =T.Jy ,....) . ::-:::tC) ,.,. .:~~ ::;, ---I .-=2 = :i, r"..] .< .- 1- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NO. 05-6209 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ" sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 121 North Sporting Hill Road, (Hampden Township), Mechanicsburg, PA 17050. 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name a record Name and address of every judgment creditor lien on the real property to be sold: Address whose judgment is None ~ ~... 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other has knowledge who has any interest affected by the sale: Name person of whom the plaintiff in the property which may be Address Tenants/Occupants 121 North Sporting Hill Road (Hampden Township) Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: January 25, 2006 8 < '" , ~2 '"'" = s~~ o -0' -l :J:-n fTIF;; =TI C? ;:~?t() "'-1, ~-..~f~ ~~-:j "1J :--< L... s; "" "'" --,~ -',.. C:J N ~ ~ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Your house (real estate) at 121 North Sporting Hill Road (Hampden Township), Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 a.m. in the Comissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,621.35, obtained by plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffls Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The saoner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find Qut if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 n c ~ f<,:':".:> J' <- -','7l,. ...::..~.~ .'- c-.:) - ,-) '-n :1-n "n~ \ I_I -'-'0 ~31...J I",."S.,, "',- -"n .~~:~ r~ ....71' ::.1":: - - ~ ~~ : ~-,.. .~ ,-, ~ ....) , , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Your house (real estate) at 121 North Sporting Hill Road (Hampden Township), Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 7, 2006 at 10:00 a.m. in the Comissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,621.35, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffrs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,,4 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. TO find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ,~; -- (') ~~ "-.,. 1 ~ r-> =' r:,:::,) W..." '- """ Z <.,) ."- ~ ~.:.. - ~ ..... ::r:..,., P1F -,:"'lIT' -,JO ;'::J,() '-~:'!, :\'~ ;,s,~ -,-'" ~ o \",,) - T I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PL AS CIVIL DIVISION Cumberland County v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 civil AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa. .C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Not~ce of Sheriff's Sale, a tru wh~ch is attached hereto as Exhibit "A", was sent lienholder and every other interested party known filing of the Praec~pe for the Writ of Execution, on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defend and certified mail on the date appear~ng on the at which was signed for by Defendant(s) on the date s Return Receipt. Copies of the said Notice and Ret hereto as Exhibi t "B". and correct copy of o every recorded s of the date of the n the date(s) appearing by regular mail ached Return Rece~pt, ecified on the said rn Receipt are attached BY: was by of Service, 3. If a Return Receipt is not attached hereto, t personal service on the date specified on the atta attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof Order is attached hereto as Exhib~t "BU. f compliance with said All Notices were served within the time 3129. Rule C.P. This Affidavit is made subject to the p relating to unsworn falsification to aut Section 4904 Dated: May 19, 2006 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATT RNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 MORTGAGE FORE Plaintiff v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NO. 05-6209 Civil Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, SQ., sets forth as of the date the Praecipe for the Writ of Execu ion was filed the following information concerning the real prop rty located at: 121 North Sporting Hill Road, (Hampden Townshi ), Mechanicsburg, PA 17050. Jimmy L. Betz 121 North Spo ting Hill Road Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Name Address Jody M. Betz 692 Cumberlan Point Circle Mechanicsburg, PA 17055-5491 2. Name and address of Defendant(s) in the Name Address SAME AS #1 ABOVE 3. Name a record Name and address of every judgment credito lien on the real property to be sold Address whose judgment is None 4. Name and address of the last recorded of record: Name Address I ! , , I I hOldet 1 i , of every mortgage Plaintiff herein. See Caption ab ve. MERS, Inc. P.O. Box 2026, F int, MI 48501-2026 5. Name and address of every other person who as any record lien on the property: Name Address None 6. Name and interest in the sale: Name address of every other person who the property and whose interest ma as any record be affected by Address Real Estate Tax Dept. 1 Courthouse S are Carlisle, PA 1 013 Domestic Relations Section 13 N. Hanover treet Carlisle, PA 1 013 PA Department of Revenue Bureau of Compliance P.O. Box 28123 Harrisburg, PA 17128-1230 7. Name and address of every other person of w om the plaintiff has knowledge who has any interest in the prop rty which may be affected by the sale: Name Address Tenants/Occupants 121 North Spor ing Hill Road (Hampden Towns ip) Mechanicsburg, PA 17050 I verify that the statements made in this affi correct to the best of my personal knowledge 0 belief. I understand that false statements he subject to the penalties of 18 Pa.C.S. sec. 49 unsworn falsification to authorities. avit are true and information and ein are made 4 relating to DATED: May 19, 2006 .C. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 plaintiff ATTJumy FOR PLAINTIFF i COURT OF COMM N PLEAS CIVIL DIVISIO Cumberland Co nty NO. 05-6209 C vil v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) . DATE: January 25, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) : Jimmy L. Betz and Jody M. Betz PROPERTY: 121 North Sporting Hill Road (Hampden Township) Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled 0 be sold at the cumberland County Sheriff's Sale on June 7 200 , at 10:00 a.m., at the Commissioners Hearing Room 2nd Floor, Court ouse, Carlisle, PA. Our records indicate that you may hold a mor gage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by t e Sheriff on a date specified by the Sheriff not later that 3 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days af er the filing of the schedule. XHIBIT A I ~ ~ .. - .. " E e" .o.Ja: ~ Ill.. u15 . i~;l~,; l!.~~gj ~ tU~~l ~!iih Eii~~E_ He=H ~Ifi~~ ~~d~:; ,,_1.~c' l!!-! 0 >. Ib.E I~l -l~!d ~:!i!iH~ lUlU I~ih~ -i~h~ ~~8.~~1 U~iE~ Ugl!.m:s H~f~ · h;=~~ t '5aJiEi~ nUn Hld~ . :iiB criu. . " . -ciB <<l ~il 'S criu.. il-.!II ., iP= "'" -l1'0 ~a;~ ';h ~ a: Cli E~ 11"- :6..'OH 13 '-80 ill 1~8 ~n ~8- "i" ~ ~ - l'! ,,>.. o c " - ~!! i ~~~ en Idfi~ ~i~"8 ~1~lf ,g ~ I i'ii ~ d.li D~DD ~..r' ~ 8t:';~~ ;.n:. \-1 ~ ~~': ,~"" " ,~j~:~~-:,-',~J;_1,i~::~,< it'" - . ~" IA';""~ '."}, .;.~i.~.L~ .,\,,\,,~ i(i~"~~~,,(~~r~~~F:f~~: .: . .~ ~ ! >- I .a I, 1 I""~ ~ -"""':f::- .! '0 .. ~ ~ ::J I :s. 2 '--Ll' E i ~"ti. 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'" ~::l '" ... .... 0 \~ ... E,XH\B\T A. ... ~ . . ) . Mortgage Electronic Registration System, Inc VS Jimmy L. Betz and Jody M. Betz The Court of commo~ Pleas of Cumberland County, ennsylvania Writ No. 2005-6209 ivil Term Brian Barrick, Deputy Sheriff, who being duly sworn accor ing to law, states that on March 15,2006 at 7:15 o'clock PM, he served a true copy ofth within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitle action, upon the within named defendant, to wit: Jimmy L. Betz, by making known to Jimmy L. Betz, personally, at 121 West Sporting Hill Road, Mechanicsburg, Cum erland County, Pennsylvania, its contents and at the same time handing to him per onally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn acco ing to law, states that on March 15, 2006 at 7:33 o'clock PM, he served a true copy ofth within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitle action, upon the within named defendant, to wit: Jody M. Betz, by making known to Jody M. Betz, personally, at 692 Cumberland Point Circle, Mechanicsburg, Cum erland County, Pennsylvania, its contents and at the same time handing to her per onally the said true and correct copy ofthe same, Robert Bitner, Deputy Sheriff, who being duly sworn acco ding to law, states that on April 05, 2006 at 11 :44 o'clock A.M., he posted a true copy of e within Real Estate Writ, Notice, Poster and Description, in the above entitled action, pon the property of Jimmy L. Betz and Jody M. Betz located at 121 North Sporting H' 1 Road, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn accordin to law, states he served the above Real Estate Writ, Notice, Poster and Description 'n the following manner: The Sheriff mailed a notice of the pendency of the actio to the within named defendant, to wit: Jimmy L. Betz, by regular mail to his last kno address of 121 N. Sporting Hill Road, Mechanicsburg, P A 17050. This letter was m 'led under the date of April 03, 2006 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn accordin to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the actio to the within named defendant, to wit: Jody M. Betz, by regular mail to her last kno address of 692 Cumberland Pointe Circle, Mechanicsburg, P A 17055. This lette was mailed under the date of April 03, 2006 and never returned to the Sheriffs Office. This _ Day of So AnSp- 0~ .~~~ R. Thomas Kline, S Sworn and Subscribed to Before Me 2006, A.D. Prothonotary EXHIBIT B () ,..., ~ c? C c.::> 0' .0:::.,.. :J!. :.J:l -n , n' "... rn:!J .. ~: r \:1f'f1 .. (..') .,nc-:J ,{\ ~~ (~) -,.- -c, :D" Gl~q -'."'" - '- 0 (Sf'll , --< -;.;. ~ "';:-1 c- .-< N '< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PEAS CIVIL DIVISION Cumberland County v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa. .C.P.RULE 3129.1 Plaintiff, by its/hiS/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of wh~ch is attached hereto as Exh~bit "A", was sent t every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, 0 the date(s) appearing on the attached Certificates of Ma~ling. 2. A Notice of Sheriff's Sale was sent to Defenda and certified mail on the date appearing on the att which was s~gned for by Defendant(s) on the date sp Return Receipt. Copies of the said Notice and Retu hereto as Exhibit "B". t(s) by regular mail ched Return Receipt, cified on the said n Receipt are attached 3. If a Return Receipt is not attached hereto, th personal service on the date specified on the attac attached hereto as Exh~bit "B". n service was by ed Return of Service, 4. If service was by Order of Court, then proof 0 Order is attached hereto as Exhibit "B". compliance with said All Notices were served within 3129. This Affidavit is made subject to relating to unsworn falsification orth by Pa Rule C.P. 8 Pa.C.S. Section 4904 Dated: May 19, 2006 BY: , EsquJ.re Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 AT ORNEY FOR PLAINTIFF National C~ty Mortgage 3232 Newmark Drive Miamisburg, OH 45342 Co. COURT OF CO CIVIL DIVISI Cumberland C ON PLEAS N unty Calvin T. Sigler, Jr Kathleen A. Sigler 318 Indian Creek Drive Mechanicsburg, PA 17050 NO. 05-5919 ivil Term Plaintiff MORTGAGE FOR CLOSURE v. Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Co., Plaintiff in the a attorney, Mark J. Udren, ESQ., sets forth as 0 Praecipe for the Writ of Execution was filed t information concerning the real property locat Woodcrest Drive, Mechanicsburg, (Hampden Twp.) ove action, by the date the e following d at: 449 PA 17050 its Kathleen A. Sigler 318 Indian Creek Mechanicsburg, PA 1. Name and address of Owner(s) or reputed Name Address Calvin T. Sigler, Jr. 318 Indian Creek Mechanicsburg, P 2. Name and address of Defendant(s) in the Name Address SAME AS #1 ABOVE 3. Name a record Name and address of every judgment creditor lien on the real property to be sold: Address hose judgment is NONE 4. Name and address of the last recorded hold r of every mortgage of record: Name Address Plaintiff herein. See Caption National City Bank P.O. Box 5570, leveland, OH 44701 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and interest in the sale: Name address of every other person who the property and whose interest ma as any record be affected by Address Real Estate Tax Dept. 1 Courthouse Squ re Carlisle, PA 170 3 Domestic Relations Section 13 N. Hanover St eet Carlisle, PA 170 3 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 1 128-1230 7. Name and address of every other person of w om the plaintiff has knowledge who has any interest in the prop rty which may be affected by the sale: Name Address Tenants/Occupants 449 Woodcrest Dri e, Mechanicsburg, (Hampden Twp.) P 17050 Good Hope Farrms 509 Sarah Court Mechanicsburg, PA 17050 I verify that the statements made in this affid correct to the best of my personal knowledge or belief. I understand that false statements he subject to the penalties of 18 Pa.C. . sec. 4 0 unsworn falsification to authorities vit are true and information and in are made relating to N DATED: May 19, 2006 Mark J. Udre , Esquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 National City Mortgage Co. 3232 Newmark Drive Miamisburg, OR 45342 Plaintiff A TORNEY FOR PLAINTIFF COURT OF COMMON PEAS CIV~I.~~IGN-- Cumberland County v. Calvin T. Sigler, Jr Kathleen A. Sigler 318 Indian Creek Drive Mechanicsburg, PA 17050 Defendant(s) NO. 05-5919 civil Term DATE: December 27, 2005 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Calvin T. Sigler, Jr and Kathleen A. Sig er PROPERTY: 449 Woodcrest Drive, Mechanicsburg, (Ham den Twp.) PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be s County Sheriff's Sale on June 7, 2006, at 10:00 am, Hearing Room, 200 Floor, Courthouse, Carlisle, PA. that you may hold a mortgage or judgment on the p extinguished by the sale. You may wish to atten your interests. ld at the Cumberland at the Commissioners Our records indicate operty which will be the sale to protect A Schedule of Distribution will be filed by th Sheriff on a date specified by the Sheriff not later that 30 days aft r sale. 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'I:> f 'a E o u .8 i t III .r '1 II: 'l; i -; = S E .. ~ .2 f~ "@ 0.. :f H ll.._ '6i'l ~o.. - .llli ... ~ll 8l z> ~ H ~ III ....0: 2 ... ~ CD u.. ~ o..~ _<D CD 0.., .. ~" U E ~~ 0 ell u. (J) '" ~3 a. ~ !:'YHIRIT A National City Mortgage Co. VS Calvin T. Sigler, Jr. and Kathleen A. Sigler I I I i , In the Court of Cfmmon Pleas of Cumberland Cou ty, Pennsylvania Writ No. 2005-5 19 Civil Term . , . . Brian Barrick, Deputy Sheriff, who being duly sworn accord' g to law, states that on March 09, 2006 at 1:58 o'clock PM, he served a true copy of the wi n Real Estate Writ, Notice and Description, in the above entitled action, upon the within named efendants, to wit: Calvin T. Sigler, Jr. and Kathleen A. Sigler, by making known unto Kathleen A. Sigler, personally and wife of Calvin T, Sigler, Jr., at 318 Indian Creek Drive, Mechanicsb , Cumberland County, Pennsylvania, its contents and at the same time handing to her person lly the said true and correct copy ofthe same. Robert Bitner, Deputy Sheriff, who being duly sworn accordin to law, states that on April 05, 2006 at 11:13 o'clock A.M., he posted a true copy of the wi in Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the roperty of Calvin T. Sigler, Jr. and Kathleen A. Sigler located at 449 Woodcrest Drive, Me hanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to aw, states he served the above Real Estate Writ, Notice, Poster and Description in the followin manner: The Sheriff mailed a notice of the pendency of the action to the within named de:D dants, to wit: Calvin T. Sigler, Jr. and Kathleen A. Sigler by regular mail to their last known a dress of 318 Indian Creek Dr., Mechanicsburg, P A 17050. These letters were mailed under the d te of April 03, 2006 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of R. Thomas Kline, Sheriff BY dcfltr1 -mLt~ Real Estat Sergeant 2006, A.D. Prothonotary ." _..-01._.. .....,\r' EXHIBITB n ,--. r--> = .'::::J. ;:'.--, ~ 'l!::!J rllr '""{:-ocr. ~ri~I' ~-;l~) -:J ~" '(~;~; <? ~ ~ -:r.. ~ (~, ,. ~. ~. .e- N COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ACE Securities Crop Home Eq Ln Trust tr is the grantee the same having been sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 31 st day of January, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 6209, at the suit of Mortgage Elec Reg Systems Inc against Jimmy L Betz & Jodv M is duly recorded in Deed Book No. 275, Page 3593. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 11 day of ~tL! , A.D. ;;-.to~, lth1A-~~ (3. ~, ~ U Recorder of Deeds RtconItr 01 DetdI, CurnbetIInd t"....-. ,......... My~Elrpne"Fht~;;-.:o '11 Mortgage Electronic Registration System, Inc VS Jimmy L. Betz and Jody M. Betz The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-6209 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 15,2006 at 7:15 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jimmy L. Betz, by making known unto Jimmy L. Betz, personally, at 121 West Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 15,2006 at 7:33 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jody M. Betz, by making known unto Jody M. Betz, personally, at 692 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 11 :44 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jimmy L. Betz and Jody M. Betz located at 121 North Sporting Hill Road, Mechanicsburg, Pennsylvania, according to law, R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jimmy L. Betz, by regular mail to his last known address of 121 N. Sporting Hill Road, Mechanicsburg, P A 17050. This letter was mailed under the date of April 03, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jody M. Betz, by regular mail to her last known address of 692 Cumberland Pointe Circle, Mechanicsburg, P A 17055. This letter was mailed under the date of April 03, 2006 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 07,2006 at 10:00 o'clock A.M. He sold the same for the sum of$15,000.00 to Attorney Mark Udren for HSBC Bank USA, National Association as Trustee, in trust for the registered holders of ACE Securities Corp. Home Equity Loan Truste, Series 2004- FM2 (MERS is actinglhas acted as the agent for the real party in interest or beneficial owner). It being the highest bid and best price received for the same, HSBC Bank USA, National Association as Trustee, in trust for the registered holders of ACE Securities Corp. Home Equity Loan Truste, Series 2004-FM2 (MERS is '. acting/has acted as the agent for the real party in interest or beneficial owner) of 4828 Loop Central Drive, Houston, TX 7708 i, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$I,500.00. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed $30.00 300.00 15.00 15.00 30.00 10.00 .50 1.00 33.44 1.08 15.00 30.00 479.00 410.00 19.57 25.00 41.50 $1,456.09 ~~ - ~ R. Thomas Kline, Sheriff BY \.J~ ~ JrvUih Real Estate ergeant ~ (V~ lfb jO' I &/{l . Ch..,)'f f'{, I ~ IUD 11 ~. . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 NO. 05-6209 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Mortgage Electronic Registration Systems, Inc., Plaintiff in the above action, by its attorney, Mark J. Udrenr ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 121 North Sporting Hill Road, (Hampden Township), Mechanicsburg, PA 17050. 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS # 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None ~ 4. Name and address of the l~st recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and interest in the sale: Name address of every other person who has any record the property and whose interest may be affected by Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other has knowledge who has any interest affected by the sale: Name person of whom the plaintiff in the property which may be Address Tenants/Occupants 121 North Sporting Hill Road (Hampden Township) Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: January 25, 2006 ~ I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Your house (real estate) at 121 North Sporting Hill Road (Hampden Township), Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 a.m. in the Comissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,621.35, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ YOU MAY STILL BE ABLE TO SAVE-YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 I UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. 4828 Loop Central Drive Houston, TX 77081 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. Jimmy L. Betz Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Defendant(s) NO. 05-6209 Civll NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jimmy L. Betz 121 North Sporting Hill Road Mechanicsburg, PA 17050 Your house (real estate) at 121 North Sporting Hill Road (Hampden Township), Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on June 7, 2006 at 10:00 a.m. in the Comissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $116,621.35, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ # YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN HAMDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH SURVEY AND PLAN THEREOF MADE BY GERRIT J. BETZ, REGISTERED SURVEYOR, DATED April 16, 1979, AS FOLLOWS: BEGINNING AT A POINT MARKED BY AN IRON PIN, ON THE WESTERN~IDE OF SPORTING HILL ROAD, SAID POINT BEING 100 FEET SOUTH OF THE SOUTHWEST CORNER OF SPORTING HILL ROAD AND AN UNNAMED STREET; THENCE ALONG THE WESTERN SIDE OF SPORTING HILL ROAD, SOUTH 18 DEGREES 30 MINUTES WEST, 73 FEET TO AN IRON PIN AT A CORNER OF LAND FORMERLY OF A. L. RUNK AND NOW OR LATE OF L. GILMORE; THENCE ALONG SAID LAND NORTH 71 DEGREES 30 MINUTES WEST, 165 FEET TO A STAKE IN LINE OF LAND NOW OR LATE OF RONALD DEBOARD; THENCE ALONG SAID LAND AND LAND NOW OR LATE OF JENTRY, NORTH 18 DEGREES 30 MINUTES EAST, 73 FEET TO AN IRON PIN AT A CORNER OF LAND FORMERLY OF HARRY BOWERS, NOW OR LATE OF CLARENCE GRIMM; THENCE ALONG SAID LAND, SOUTH 71 DEGREES 30 MINUTES EAST, 165 FEET TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 12 AND THE NORTHERN 23 FEET OF LOT NO. 13 ON THE PLAN OF LOTS ENTITLED PLAN NO. 2 OF BUNGALOW SITES, WHICH PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 3, PAGE 24. HAVING THEREON ERECTED A ONE-STORY STUCCO AND FRAME DWELLING KNOWN AS NO. 121 N. SPORTING HILL ROAD. UNDER AND SUBJECT, NEVERTHELESS, TO RESTRICTIONS, RESERVATIONS AND CONDITIONS AS CONTAINED IN PRIOR ~NSTRUMENTS OF RECORD. THE SOUTHERN LINE OF THE ABOVE DESCRIBED PREMISES PASSES THROUGH THE CENTER LINE OF THE WELL LOCATED ON ,LOT NO. 13. THE SAID WELL TO BE aSED JOINTLY BY THE GRANTEE HEREIN, HIS HEIRS AND ASSIGNS, AND THE OWNERS OF OCCUPIERS OF THE SOUTHERN PART OF LOT NO. 13 AND LOT NO. 14 ON THE ABOVE MENTIONED PLAN. BEING KNOWN AS: 121 NORTH SPORTING HILL ROAD (HAMPDEN TOWNSHIP) MECHANICSBURG, PA 17050 10-20-1844-128 PROPERTY ID NO. : TITLE TO SAID PREMISES IS VESTED IN JIMMY L. BETZ AND JODY M BETZ HUSBAND AND WIFE BY DEED FROM DANIEL R. DUPERT JR A 'SINGLE PERSON AND TIMOTHY A. SNOW, A SINGLE PERSON, AS 'EQUITABLE OWNER DATED 8/23/99 RECORDED 1/7/00 IN DEED BOOK 214 PAGE 637. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6209 Civil CIVIL ACTION -LAW . TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From JIMMY L. BETZ AND JODY M. BETZ (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $116,621.35 1.1. $.50 Interest FROM 1/25/06 TO DATE OF SALE 6/7/06 - ONGOING PER DIEM OF $25.08 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $3,360.72 Atty's Comm % Due Pro thy $1.00 Atty Paid $137.52 Other Costs Plaintiff Paid Date: JANUARY 31,2006 f9J By: (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 04 On February 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 121 North Sporting Hill Rd., Mechanicsburg, more fully described on Exhibit "A" Date: February 03, 2006 By: J beLL( Jvwi~ Real Estate Sergeant (-J CVil E:ViJ c::::::I G?> &vi) filed with this writ and by this reference incorporated herein. 80 :b 'V G - 93~ qOOZ Vd 'A1NllOJ OHvHB8Wfl3 .:i.:J'~3HS 3Hl .:10331.:1.:.10 SCHEDULE OF'DISTRIBUTION SALE NO. 04 Date Filed: July 07, 2006 Writ No. 2005-6209 Civil Term Mortgage Electronic Registration Systems, Inc. VS Jimmy L. Betz and Jody M. Betz 121 North Sporting Hill Road Mechanicsburg, P A 17050 Sale Date: Buyer: Bid Price: June 07, 2006 Attorney Mark Udren for HSBC Bank USA $15,000.00 Real Debt: Interest: Attorney Costs: $116,621.35 3,360.72 137.52 Total: $120,119.59 DISTRIBUTION: Receipts: Cash on account (02/03/2006): Cash on account (06/07/2006): Cash on account (07/10/2006): Credit Writ 2005-6209 Civil Term $ 1,500.00 1,500.00 240.26 11,759.74 Total Receipts: $15,000.00 Disbursements: Sheriffs Costs Legal Search Marie Huber, Tax Collector Hampden Township Credit Writ No. 2005-6209 Civil Term Total Disbursements: Balance for distribution: So Answers: r-~~~<~~ R. Thomas Kline Sheriff $1,456.09 200.00 1,085.54 498.63 11,759.74 ($15,000.00) 0.00 TITbE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITIING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO.4 Held Wednesday, June 7, 2006 Date: June 7, 2006 T AXES: Receipts for all taxes for the years 2003 to 2005 inclusive. Taxes for the current year 2006. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2006, and recorded , 2006, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Daniel R. Dupert, Jr. and Timothy A. Snow by deed dated August 23, 1999 and recorded January 7, 2000 in the Office of the Recorder of Deeds for Cumberland County in Deed Book 214, Page 637. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Sporting Hill Road. 6. Conditions, easements and restrictions shown on or set forth on the Plan for Bungalow Sites recorded in Cumberland County Plan. Book 3, Page 24. 7. Subject to an easement for the use of a well running through the center line in common with the owner of Lot 14 as set forth in Deed Book 214, Page 637. 8. Mortgage in the amount of $ 104,800.00 given by Jimmy L. Betz and Jody M. Betz to Fremont Investment and Loan for Mortgage Electronic Registration Systems, Inc. dated March 24,2004 and recorded April 15, 2004 in Mortgage Book 1860, Page 4825. Complaint in Mortgage Foreclosure filed on December 2, 2005 filed by Mortgage Electronic Registration Systems, Inc. as Plaintiff against Jimmy L. Betz and Jody M. Betz as Defendants in the Office of the Prothonotary to file number 2005-6209. Judgment in the amount of $116,621.35 entered on January 31, 2006. 9. Mortgage in the amount of $6,550.00 given by Jimmy L. Betz and Jody M. Betz to Fremont Investment and Loan for Mortgage Electronic Registration Systems, Inc. dated March 24, 2004 and recorded April 15, 2004 in Mortgage Book 1860, Page 4847. 10. Rights granted to American Telegraph and Telephone Company by instrument recorded in Miscellaneous Record Book 39, Page 241. 11. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 12. Real estate taxes accruing on and after July 1, 2006 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court Robert G. Frey, Agent Note: This Title Report shall not be valid or bl g until countersigned by an authorized signatory. REAL ESTATE SALE NO. 4 Wrtt No. 2005-6209 Civil Mortgage Electronic Registration Systems. Inc. vs. Jimmy L. Betz and Jody M. Betz Atty.: Mark Udren ALL THAT CERTAIN lot or piece of land situate In Harnden Town- ship, Cumberland County, Pennsyl- vania, bounded and described In accordance with survey and plan thereof made by Gerr\t J. Betz, Reg- Istered Surveyor, dated Aprll 16, 1979, as follows: BEGINNING at a point marked by an Iron pin, on the western side of Sporting HIl1 Road, said point being 100 feet south of the south- west comer of Sporting HIl1 Road and an unnamed street: Thence along the western side of Sporting HllI Road, South 18 degrees 30 min- utes West. 73 feet to an Iron pin at a comer of land formerly of A. L. Runk and now or late of L. Gilmore; Thence along said land North 71 degrees 30 mlnutes West, 165 feet to a stake In line oCland now or late of Ronald DeBoard: Thence along said land and land now or late of Jen- try, North 18 degrees 30 minutes East, 73 feet to an Iron pin at a cor- ner of land formerly of Harry Bow- ers. now of late of Clarence Grimm; Thence along said land, South 71 degrees 30 minutes East, 165 feet to the point and place of beginning. BEING Lot No. 12 and the north- ern 23 feet of Lot No. 13 on the plan of lots entitled Plan No. 2 of Bungalow Sites, which plan Is re- corded In the Cumberland County Recorder's Office In Plan Book 3, Page 24. HAVING thereon erected a one. story stucco and frame dwelling known as No. 121 N. Sporting Hili Road. UNDER AND SUBJEC1', never- theless, to restrictions, reservations and conditions as contained In prlor Instruments of record. The southern Hne of the above described premlses passes through the center Hne of the well located on Lot No. 13. the said well to be used JOintly by the grantee herein. his heirs and aSSigns. and the own. ers of occupiers of the southern part of Lot No. 13 and Lot No. 14 on the above mentioned plan. BEING KNOWN AS: 121 NORTH SPORTING HILL ROAD (HAMPDEN TOWNSHIP) MECHANICSBURG, PA 17050. PROPER1Y ID NO.: 10-20-1844- 128. TITLE: TO SAID PREMISES IS VESTED IN Jimmy L. Betz and Jody M. Betz,. husband and wife by Deed from Daniel R. Dupert, Jr.. a single person and Timothy A. Snow, a single person, as equitable owner dated 8/23/99 recorded 1/7/00 In Deed Book 214 Page 637. THE PATRIOT NEWS THE SUNDAy PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State ofPennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#4 Sworn to and sub CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 '. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TB OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7,14,21,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 21 day of April. 2006 --.----- . ;-lIT RBAL ESTATB 8Al..E NO.4 Writ No. 2005-6209 Civil Mortgage Electronic Registration Systems, Inc. vs. Jimmy L. Betz and Jody M. Betz Atty.; Mark Udren ALL TIiAT CERTAIN lot or piece of land situate in Harnden Town- ship, Cumberland County, Pennsyl- vania, bounded and described in accordance With survey and plan thereof made by Gemt J. Betz, Reg- istered Surveyor, dated April 16, 1979, as follows: ~..,. BEGINNING at a point marked by an iron pin, on the western side of Sporting Hill Road, said point being 100 feet south of the south- west corner of Sporting Hill Road and an unnamed street; Thence along the western side of Sporting Hill Road, South 18 degrees 30 min- utes West, 73 feet to an iron pin at a corner of land fonnerly of A. L. Runk and now or late of L. Gilmore; Thence along said land North 71 degrees 30 minutes West, 165 feet to a stake in line of land now or late of Ronald DeBoard; Thence along said land and land now or late of Jentry, North 18 degrees 30 min- utes East, 73 feet to an iron pin at a comer of land formerly of Harry Bowers, now of late of Clarence Grimm; Thence along said land, South 71 degrees 30 minutes East, 165 feet to the point and place of beginning. BEING Lot No. 12 and the north- ern 23 feet of Lot No. 13 on the plan of lots entitled Plan No. 2 of Bungalow Sites, which plan is re- corded in the Cumberland County Recorder's Office in Plan Book 3, Page 24. HAVING thereon erected a one- story stucco and frame dwelling known as No. 121 N. Sporting Hill Road. UNDER AND SUBJECT, never- theless, to restrtctions, reservations and conditions as contained In prior Instruments of record. The southern line of the above described premises passes through the center line of the weIl Ideated on Lot No. 13. the said well to be used jointly by the grantee herein, his heirs and assigns, and the own- ers of occupiers of the southern part of Lot No. 13 and Lot No. 14 on the above mentioned plan. BEING KNOWN AS: 121 NORTH SPORTING HILL ROAD (HAMPDEN TOWNSHIP) MECHANICSBURG, PA 17050. PROPER1Y 10 NO.: 10-20-1844- 128. TITLE TO SAID PREMISES IS VESTED IN Jimmy L. Betz and Jody M. Betz, husband and wife by Deed from Daniel R. Dupert, Jr., a single person and Timothy A. Snow, a single person, as equitable owner dated 8/23/99 recorded 1/7/00 in T"\.....-.A D",,,lr I) l.1t D~N~ A~7